Answer box
Fasteners under CN 7318 — screws, bolts, nuts, washers, rivets — are in CBAM scope. Only direct emissions count for the fastener process itself (heat treatment, forming, plating), but the wire rod or billet precursor carries its own embedded emissions, which flow into the fastener’s total. Because most fastener units don’t make their own wire, EU importers typically collect data from two tiers: the fastener supplier, and their wire rod supplier.
Where fasteners come from
Big export clusters we see:
- Ludhiana (India) — bulk mechanical fasteners, cold-headed from imported wire rod.
- Taiwan — precision fasteners for automotive.
- China (Haiyan, Yongnian) — large volumes of standard DIN/ISO fasteners.
- Turkey — mid-range fasteners for construction and automotive.
The two-tier data problem
- Tier 1 — fastener supplier. Fuel, electricity (used but not counted for CBAM steel), heat-treatment energy, surface treatment energy, and production tonnes by subheading.
- Tier 2 — wire rod supplier. The embedded emissions of the wire rod (CN 7213 or 7217). Many fastener units cannot track this because they buy on open market.
If Tier 2 can’t be traced, default values plus the mark-up apply for the precursor portion only.
What to ask your supplier
- Fuel and electricity used by the fastener plant.
- Heat treatment energy — significant for hardened fasteners (property class 10.9+).
- Surface treatment energy — zinc plating, phosphating, hot-dip galvanising.
- Production tonnes by 8-digit CN code (7318.15 for machine screws/bolts, 7318.16 for nuts, 7318.11 for coach screws, etc.).
- Wire rod procurement — origin, grade (property class), mass, and any emissions data from the wire rod supplier.
Common questions
- My supplier mixes grades in one heat. The engine supports attribution across grades from the same heat.
- Can CBAMWorks reach the Tier-2 wire supplier? Yes — the fastener supplier can invite them in a separate workspace. We handle the chain.
- What about plating done by a third party? The energy for plating is attributed to the installation that performed it. If plating is outsourced, that installation’s emissions carry into the fastener.